Letter to Steve Dickson, Administrator for the Federal Aviation Administration - Norton, Quiet Skies Caucus Send Letter to FAA on Aircraft Noise

Letter

Dear Administrator Dickson:

As members of the Quiet Skies Caucus, we have deep concerns regarding the results of the Federal Aviation Administration's (FAA's) nationwide survey about aircraft noise annoyance. The results show clearly that the Day-Night Sound Level (DNL) and corresponding Schultz Curve created in the 1970s have outlived their usefulness--people are far more annoyed by aircraft noise than the Schultz Curve predicts. This validates the reports about aircraft noise we have been hearing from our constituents for years and requires the FAA to take aircraft noise more seriously than it has thus far.

After years of delay, the FAA has finally released the results of its Neighborhood Environmental Survey and issued a Federal Register Notice to seek comments on the survey results from the public. Fundamentally, the survey results demonstrate that the method the FAA uses to measure aircraft noise is deeply flawed. Even the FAA acknowledges that, "Compared with the existing Schultz Curve, the new National Curve shows a substantial increase in the percentage of people who are highly annoyed by aircraft noise over the entire range of aircraft noise levels considered, including at lower noise levels." These metrics are the very foundation of the FAA's understanding of aircraft noise in the United States. If these metrics are not reliable, that calls into question the FAA's entire framework of regulations and programs to reduce aircraft noise. It also suggests the FAA may not be doing enough because, to date, it has not understood the true scope of the problem.

This data, which has been in the FAA's possession for years, contradicts the report the FAA provided to Congress on April 14, 2020, on its findings pursuant to Sections 188 and 173 of the FAA Reauthorization Act of 2018 (P.L. 115-254). That law required the FAA to "evaluate alternative metrics to the current average day-night level standard, such as the use of actual noise sampling and other methods, to address community airplane noise concerns." In a letter many of us sent to you on September 23, 2020, we noted that the FAA's cursory, inadequate report issued pursuant to that law failed to properly evaluate well-respected and widely used alternatives to DNL, contained inaccurate comparisons of DNL to those alternatives, did not analyze any complaint data and lacked scientific nuance. Instead of a robust analysis, Congress was offered excuses such as, "No single noise metric can cover all situations."[2] That letter insisted that "the FAA return to the drawing board and meaningfully evaluate alternative metrics to the current DNL 65 average, not just dismiss or ignore them, and include the potential use of such metrics in the United States." We also sought formal responses to the questions in the appended Citizens' Response Report, a Technical Report to the FAA's April 2020 Report on Alternative Noise Metrics (Reauthorization Act of 2018, Sections 173 and 188). We have not received responses.

Though the FAA finally released the Neighborhood Environmental Study, the data is from 2015-2016, which means that it tells us what people were experiencing six years ago. This is an unacceptable lag time between data collection and publication. The FAA must collect and release data on noise complaints and annoyance levels on a regular basis if we are to create and implement effective policy solutions.

Furthermore, we appreciate that the FAA solicited comments from the public on factors that may be contributing to the heightened annoyance levels, but we hope this is the first step toward deeper engagement with affected communities. Congress provided $5 million to increase the FAA's community engagement capacity in the report accompanying the fiscal year 2021 Transportation, Housing and Urban Development, and Related Agencies Appropriations bill. This funding should provide the FAA with the resources it needs to understand the nuances of aircraft noise disturbances in different communities across the country and to bring new energy to tackling this problem in a collaborative fashion.

We request that you provide a written response to the following questions by May 10, 2021, and include this letter in the comments to the Neighborhood Environmental Survey:

Does the FAA plan to reconsider its use of DNL as its core aircraft noise metric?
Does the FAA plan to reconsider the 65 DNL level as the appropriate sound threshold for "significant" aircraft noise?
The report accompanying the FY 21 Transportation, Housing and Urban Development, and Related Agencies Appropriations bill provided an increase of $5 million for the FAA "to hire additional staff to increase the FAA's community engagement capacity, including participating in community roundtables and meetings with local officials, for contractor support to make more data about aircraft positions and altitude publicly available, to prepare air traffic histories and analyses, and to conduct environmental reviews." What is the status of hiring these new community engagement staff?
Now that this survey data has been released, what are the next steps that FAA plans to take?
Does the FAA plan to conduct additional studies on aircraft noise in the near future?
What data related to aircraft noise does the FAA collect on an ongoing basis? Is this data accessible to the public? If so, where?

Sincerely,